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HOME  /  BRIEFINGS  /  CYPRUS CITIZENSHIP BY INVESTMENT – LATEST SIGNIFICANT AMENDMENTS

BRIEFINGS

Cyprus Citizenship by Investment – latest significant amendments

The Cyprus Investment Programme (CIP) has been revised and amended in August 2020. For the purpose of expediting the examination procedures, a Naturalizations Control Unit (NCU) has been established, composed of suitably trained staff of the Ministry of Interior. The NCU is responsible for the examination of the citizenship applications, the applicants’ compliance with all relevant regulations and the general coordination and/or supervision of the CIP.

In particular, on 18/08/2020, the Council of Ministers have adopted the amended regulations in regards to the CIP, which are reflected below:

Eligibility

  • Investment of funds for the incorporation and/or establishment of a land developing company is not a qualifying investment anymore.
  • Investments through incorporation or through participation in Cyprus companies and/or corporations and/or businesses based on an investment plan is still a qualifying investment, provided that such entities have their physical presence and operations in Cyprus. Additionally, substantial activity and significant turnover must be verified, while the number of minimum Cypriot or European employees has been increased from 5 to 9.
  • The validity of the applicants’ Criminal Record (from the country of permanent residence) has been increased from 3 to 6 months from the date of issuance.
  • The list of people considered to fall into the high-risk category has now been extended. In particular, the following categories are considered as High-Risk and applicants falling in any of the following categories are not eligible to apply for the CIP:  

a)    Applicants whose assets have been subject to a seizure order within the EU;

b)    Politically Exposed Persons (PEPs)- There has been a change in the definition of who is considered a “PEP”. Under the new regulations, a PEP is a person who holds a political position at the time of submission of the application or a person who has held a political position during the last 12 months prior to the date of submission of the application. Consequently, a PEP is eligible to apply for the CIP, provided that he did not hold such position for at least 12 months, prior to the submission of the application.

c)    Applicants sentenced for a serious criminal offence which carries a sentence of five years or more or for any other serious offence or offences that involve moral obscenity. In the event that a person has been sentenced in another country, the offence he committed must be a criminal offence in Cyprus that carries a sentence of imprisonment;

d)    Applicants subject to criminal investigation, whether in Cyprus or abroad, in relation to a serious criminal offence which carries a sentence of five years or more or for any other serious criminal offence or which involves moral obscenity;

e)    Applicants who are affiliated with any person or legal entity or organisation against which sanctions were imposed by the European Union and these sanctions are still in force, such as shareholders and high-ranking officials of such companies;

f)     Applicants who were, but who no longer are, affiliated with any physical person or legal entity against which sanctions were imposed by the European Union and these sanctions are still in force, such as shareholders and high-ranking officials of companies included in the sanctions list, provided they were affiliated with these companies when the sanctions were enforced;

g)    Applicants who have been subjected to sanctions by the European Union or the United Nations and such sanctions are still in force or were in force up to twelve months prior to the submission of the application;

h)    Applicants who are affiliated with any physical person or legal entity against which sanctions were imposed by the European Union or the United Nations and these sanctions are still in force or were in force up to 12 months prior to the submission of the application;

i)     Applicants who were affiliated with any physical person or legal entity against which the EU or the United Nations have imposed restrictive measures and such restrictive measures are in force or were in force up to twelve months prior to the submission of the application, but these applicants are no longer affiliated with these legal entities, such as shareholders and high-ranking officials of companies, provided they were affiliated to the particular companies or physical persons when the sanctions were imposed;

j)     Applicants who are wanted at a European level by Europol or at an International level by Interpol.

Financial Criteria and mandatory donation

Regarding the financial criteria of the CIP, these remain the same apart from the mandatory donation which has been increased from €150,000 to €200,000, out of which the €100,000 must be donated to the Cyprus Land Development Corporation and the remaining €100,000 to one of the following:

  • The Research and Innovation Foundation; or
  • The Industry and Technology Service; or
  • The Fund for Renewable Energy Sources and Conservation of Energy; or
  • The National Solidarity Fund.

Family members

Family members of an investor who successfully applies for naturalization under the CIP may also be naturalized provided they fulfill all the criteria. The government has introduced flexibility in the manner of submitting the application of the investors and their dependent family members. Such an application may now be submitted either at the same time or after the application of the main applicant/investor. Additionally, the applicant or the applicant’s family members must not have taken any actions which manifest that they accept in any way the illegal administration of the non-controlled by Government of the Republic of Cyprus areas. They must not have any official post or position there and they must not have trespassed or in any way caused any damage to immovable property located in those areas that belong to another lawful owner.

Parents of the investor’s spouse

Further, the parents of the spouse of the main applicant can now apply for Cyprus Citizenship in addition to the parents of the main applicant, provided they also own a permanent private residence in Cyprus worth at least €500,000 plus VAT.

The citizenship status may be revoked if any of the financial criteria and/or requirements of the CIP are no longer satisfied.

The amendments introduced aim at strengthening the status of the Cyprus Investment Programme. It is also noteworthy here that foreign nationals seeking the Cypriot passport will now be able to invest in sectors other than real estate, such as the primary sector, research and development, technology, healthcare and renewable energy sources.

N. Pirilides & Associates LLC has been duly registered on 02.11.2018 in the Registry of “Service Providers for the Cyprus Investment Programme” with reg. no. 432.

For any further enquiries you may contact us at info@pirilides.com.